(www.MaritimeCyprus.com) Each year, PSC regimes identify a specific focus area to be checked during regular inspections. For the current year, the Paris and Tokyo MoUs agreed to run a CIC on the topic of crew wages and Seafarer Employment Agreements under MLC. It is expected that the financial security requirements under the 2014 amendments to the MLC are also covered by this CIC.
The majority of PSC MoUs have confirmed their participation in this year’s CIC. It will be carried out between 1 September and 30 November and will be covered by an additional questionnaire during routine PSC inspections.
This additional questionnaire is usually published in early August. Once the final questionnaire is published, we will update this article.
Statistics reveal that, across three different topics, most findings in this area align with the following examples:
Wages
Seafarer Employment Agreements (SEAs)
Financial security 2014 amendments
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It should be noted that the CIC is part of regular PSC inspections, and the attending PSC Officer may extend the inspection to other areas of the ship or crew-related matters, such as rest hour records or familiarization. Furthermore, several non-detainable MLC-related deficiencies can likely trigger an ISM deficiency (PSC Code 15150), even as the only ground for detention.
Management systems and PSC
Due to additional international requirements, a PSC inspection will not only focus on technical issues but also take a more systematic approach to evaluate the vessel’s management system implementation. Evidence of improvement needs can be technical issues (e.g. malfunctions due to low maintenance level) as well as operational matters (e.g. familiarization by / training of crew or unawareness of malfunctions). Over the past years, ISM deficiencies have consistently ranked as the most common detainable issue during ship detention.
Owners/Managers should prioritize having well-implemented management systems for ISM, ISPS and MLC. These aim to maintain the awareness of the vessel’s status and to promptly implement effective mitigation actions, if necessary, ideally ensuring compliance at all time.
It is recommended that companies conduct root cause analyses, including corrective and preventive actions, for individual PSC deficiencies. This data, statistics and resulting improvement needs should be included in the annual management reviews for the evaluation of effectiveness.
Recommendations
Owners/Managers should make sure that all the necessary and required information about working arrangements and payment are available to crews. Masters should be informed about the planned CIC and which documents are expected to be requested during inspection.
As deficiencies about MLC are directly linked to the implementation of the Safety Management System (SMS), the SMS should be reviewed for any necessary updates. It is also recommended to perform root cause analyses for individual PSC deficiencies.
You can download below a Guidance paper for port State control inspections on this PSC CIC, from Paris MoU:
Download the relevant checklist, by clicking HERE.
Source: Paris MoU
